Principles and principle-wise performance disclosures

Principles and principle-wise performance disclosures

Business Responsibility Report (BRR)Business Responsibility and Sustainability Report (BRSR)
Principle-wise performancePrinciple-wise performance disclosures (details of additional disclosures)
PRINCIPLE 1:PRINCIPLE 1:
Businesses should conduct and govern themselves with Ethics, Transparency and AccountabilityBusinesses should conduct and govern themselves with integrity and in a manner that is ethical, Transparent and Accountable
Disclosure of description of training and awareness programmes on any of the principles held for the board of directors, KMPs, employees other than board members and workmen.
Disclosure of fines / penalties / punishment / award / compounding fees paid / settlement amount paid in any proceeding against company and it’s KMPs in the current year. The disclosure also need to include non-monetary penal provisions such as punishment / imprisonment.
The disclosure is required to be made as per the provisions of regulation 30 of LODR on the basis of materiality.
Disclosure relating to conflicts of interest of the directors and KMPs – number of complaints during the current year.
Disclosure relating to corrective action taken / initiated / underway by the company on issues related to fine/ penalties/ action taken by regulators and law enforcing agencies on cases of conflicts of interest and corruptions.
Disclosure of company’s policy on anti-corruption /anti-bribery. Any disciplinary action taken by the company against director / KMPs against charges of corruption bribery – for the current year and also for previous year.
PRINCIPLE 2:PRINCIPLE 2:
Business should provide goods and services that are safe and contribute to sustainability throughout their cycleBusiness should provide goods and services in a manner that is sustainable and safe.
Disclosure relating to percentage of R & D / capital expenditure / investment made by the company in specific technologies to improve environmental and social impacts of the company’s products and processes against its total R & D and capital expenditure investment – for the current year and previous year.
Procedures in place for sustainable sourcing (if any) indicating the percentage of input sourced in a sustainable way.
Company is required to state whether responsibility of a producer for the environmental sound management of the product until the end of its life (EPR) is applicable.
If the answer is ‘Yes” further disclosures on waste collection plan is in line with the ERP plan submitted to the pollution control board by the company.
Disclosure relating to details of life cycle assessment (LCA) is applicable to any of the products / services of the company along with disclosures on significant social or environmental concerns and or risk arising from production or disposal of the products / services and the mitigation action taken by the company.
Process put in place for safe collection / reuse / recycle and disposal of products at the end of life cycle separately for (i) plastic including packaging; (ii) e-waste; (iii) hazardous waste and (iv) other wastes.
PRINCIPLE 3:PRINCIPLE 3:
Businesses should promote the well-being of all employeesBusinesses should promote the well-being of all employees including in their value chain.
Measures taken by company relating to wellbeing of the employees in the current year along with details for previous year.
PRINCIPLE 4:PRINCIPLE 4:
Business should respect the interests of and be responsive towards all stakeholders especially those who are disadvantaged, vulnerable and marginalizedBusiness should respect the interests and be responsive to all its stakeholders
Disclosure about the process in place for identifying key stakeholder groups of the company along with providing details relating to frequency of engagement with each stakeholders group
Disclosure as to company’s premises / offices – accessibility to differently abled employees / workers.
Policy disclosure on equal opportunity policy pursuant to Rights of Persons Disabilities Act 2016
Mechanism for receiving complaints and addressing them for employees and workers including non-permanent employees and workers.
Details of performance and career development reviews undertaken by the company and also confirmation these reviews are done with the knowledge of the employees.
Details of corrective action taken by company / action underway for addressing the risk and concerns relating to health and safety practices and working conditions of value chain partners.
PRINCIPLE 5:PRINCIPLE 5:
Business should respect and promote human rightsBusiness should respect and promote human rights
Disclosure of training provided to employees / workers on company policies and human right issues for current year vis-à-vis previous year.
Additional disclosures called for if the company is having a committee which is responsible to address the human right issues or issues caused or contributed to by the business.
Disclosure of minimum wages paid to employees / workers (both for permanent and non-permanent)
Disclosure of mechanism in place to protect the complainant from adverse consequences relating to discrimination and harassment cases
PRINCIPLE 6:PRINCIPLE 6:
Business should respect, protect and make efforts to restore the environmentBusiness should respect, protect and make efforts to restore the environment
Specific disclosures are called for in respect of water withdrawal / discharge inclusion source / destinations – example – surface water / ground water / third party water – for current year and previous year.
PRINCIPLE 7:PRINCIPLE 7:
Business when engaged in influencing public and regulatory policy should do so in a responsible mannerBusiness when engaged in influencing public and regulatory policy should do so in a manner responsible and transparent
Disclosure relating to details relating to trade and industry chambers / associations, the company is member of / affiliated to.
Corrective action taken / being taken by company on any issue relating to anti-competitive conduct by the company based on adverse orders received by the regulatory authorities
PRINCIPLE 8:PRINCIPLE 8:
Business should support inclusive growth and developmentBusiness should promote inclusive growth and equitable development
Disclosure required on social impact assessment (SIA) of projects undertaken by the company based on applicable law in the current year and also disclosure about projects for which ongoing rehabilitations and assessments is being undertaken by the company.
Disclosure of preferential procurement policy in cases of purchases from supplies comprising marginalized / vulnerable groups.
PRINCIPLE 9:PRINCIPLE 9:
Business should engage with and provide value to their customers and consumers in a responsible mannerBusiness should engage with and provide value to their customers in a responsible manner
Disclosure called for on number of consumers complaints received during the current year –vis-s-vis previous year, data privacy, advertising, cyber security, unfair trade practices along with details relating to mechanism in place to receive complaint, respond complaint and feedback
Policy of the company on cyber security and risk related to data privacy and the website link where the policy is displaced

What is BRSR?

Sustainability Reporting is an emerging discipline encompassing the disclosure and communication of an entity’s non -financial – environmental, social, and governance (ESG) performance and its overall impact. Over the last few years, more and more entities are now preparing and disclosing their sustainability reports either under a mandate or voluntarily as per the reporting frameworks/ standards provided by standard-setting bodies/ regulators.
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Foundation stone for BRSR

There are various international and local frameworks used by organisations across the globe for their corporate sustainability reporting. In November 2018, the Ministry of Corporate Affairs (MCA) constituted a Committee on Business Responsibility Reporting for finalising Business Responsibility Reporting formats for listed and unlisted companies, based on the framework of the National Guidelines for Responsible Business Conduct’ (NGRBCs) . Note:   The existing format of BRR is based on ‘National Voluntary Guidelines on Social, Environmental and Economic Responsibilities of Business’ (“NVGs”) issued by the Ministry of Corporate Affairs (“MCA”), Government of India.
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Key disclosures in BRSR

A few of the key disclosures sought in the BRSR are highlighted below: a. An overview of the entity’s material ESG risks and opportunities, approach to mitigate or adapt to the risks along-with financial implications of the same
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Role of Chartered Accountants in BRSR

“The focus on sustainable investing among equity market participants is expected to rise with more companies and countries implementing policies to meet ESG targets, particularly with respect to carbon emissions…….Stocks in Asia with high ESG scores on the MSCI are trading at a 40% premium to stocks with low ESG scores
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